TTB Proposed regulation 160 and 160B

[wxtrendsguy]

Does anyone know the status of the proposed regulation that TTB made in 2016 and then reopened the comment period in 2017 through early 2018. What I have read from earlier this year was that a decision was going to be coming in a few months...well that was 7 months ago.

For those that are not familiar it had to do with trying to close a loophole in the TTB AVA labeling rules. The weird thing is I see a commercial winery in CA called Siduri who is well known for their versions of Pinot Noir that they source from all over California and Oregon. Funny thing is the Pinot from Oregon is made into wine at their winery in California yet on the label they proudly proclaim Willamette Valley as the AVA which is not allowed as far as I understand TTB rules unless they claim the TTB label exemption and use the text on the label that says "for sale in CA only".

The other interesting aspect of the loophole I see is under the same regulation I do not have to list an AVA at all nor follow almost any of the ttb label rules if I claim the in-state for sale only exemption....so why is this important well it means a so called business who calls themselves a winery in PA or any other state can just buy bulk wine from California, bottle it at their so called winery and the label can easily say something like

Pennsylvania Winery and Vineyards
PINOT NOIR
2016

As long as you meet your state's label regulations which usually means an address and the health warning there is nothing there requiring you to identify that you ever made the wine, or where it was grown or pretty much anything else....It just blows me away and so dishonest....

 

[wxtrendsguy]

So I was able to answer a small part of the above. Turns out Siduri winery is owned by Jackson Family Wines, Inc. and not only do they produce in Sonoma County, CA they also have production facilities in Oregon. So that is how they are being allowed to use the AVA on the label. Both growing and vinifying in theory are being done in Oregon...not sure that is the case based on what I have read on their website but its good enough for the ttb I guess.

 

[Brigitte]

Does anyone know the status of the proposed regulation that TTB made in 2016 and then reopened the comment period in 2017 through early 2018. What I have read from earlier this year was that a decision was going to be coming in a few months...well that was 7 months ago.

For those that are not familiar it had to do with trying to close a loophole in the TTB AVA labeling rules. The weird thing is I see a commercial winery in CA called Siduri who is well known for their versions of Pinot Noir that they source from all over California and Oregon. Funny thing is the Pinot from Oregon is made into wine at their winery in California yet on the label they proudly proclaim Willamette Valley as the AVA which is not allowed as far as I understand TTB rules unless they claim the TTB label exemption and use the text on the label that says "for sale in CA only".

The other interesting aspect of the loophole I see is under the same regulation I do not have to list an AVA at all nor follow almost any of the ttb label rules if I claim the in-state for sale only exemption....so why is this important well it means a so called business who calls themselves a winery in PA or any other state can just buy bulk wine from California, bottle it at their so called winery and the label can easily say something like

Pennsylvania Winery and Vineyards
PINOT NOIR
2016

As long as you meet your state's label regulations which usually means an address and the health warning there is nothing there requiring you to identify that you ever made the wine, or where it was grown or pretty much anything else....It just blows me away and so dishonest....

I’m trying to learn the labeling laws myself. We are in the process of starting a winery. Awaiting TTB permits at present. Our winery/vineyard is not in an AVA. I believe there are regulations about providing where bottling occurs.. etc. I need to read that over again.

 

[ffemt128]

I recently ran into s similar situation, I have an Italian juice which was imported. TTB told me to use either "Pnnsylvania Table Wine" or "American Table Wine" as the appellation as the juice was fermented and bottled in PA. I originally tried to submit it as both a domestic and using just "Red Table Wine" but was told the appellation was needed even though there was no varietal listed.